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DRILLING THROUGH SHENANDOAH MOUNTAIN

Dominion has responded to concerns about impacts to the rare Cow Knob salamander with an extreme proposal to drill though Shenandoah Mountain. The so-called horizontal directional drilling would involve two separate sections of 1.3 and 1.1 miles. Damage to Cow Knob salamander habitat would not be completely avoided, a native brook trout stream would be unavoidably damaged, and a critical karst system would be placed at unacceptable risk. The following article from The Recorder is reprinted with permission.

DOMINION CHOOSES DRILLING OVER MAJOR ROUTE CHANGES

by John Bruce, 11/5/15

MONTEREY — An energy company’s plan to bore through a mountain and protect a threatened species would nonetheless harm its habitat and pollute water, a scientist said.

Rick Webb of Mustoe, a retired University of Virginia scientist, pipeline opponent, and [Coordinator] of the Dominion Pipeline Monitoring Coalition, said horizontal drilling would damage water supplies and leave the home of the threatened Cow Knob salamander partly in harm’s way.

Dominion would drill through Shenandoah Mountain in efforts to preserve the salamander’s habitat, based on a secondary recommendation of the U.S. Forest Service, to accommodate the proposed Atlantic Coast Pipeline.

The forest service advised federal regulators that one way to address issues with the pipeline route through the habitat was to reroute the path. That would mean a substantial alteration of the pipeline route.

Another way was to bore through the mountain and leave the ridge intact for salamanders, recreation and reduce illegal ATV traffic.

Boring “would not avoid all impacts to habitat and salamanders because it would not completely avoid salamander habitat,” the forest service said in a mid-September filing with the Federal Energy Regulatory Commission. The forest service argued that open-trench construction could wipe out the tiny mountain-dwelling amphibians, thought to be endangered.

The drilling proposal was the second of two alternatives the forest service presented. The first was to select a new pipeline route that, unlike the drilling alternative, would avoid the salamander habitat entirely. The new route would need to be south of Chestnut Ridge and South Sister Knob or north of Romney, W.Va, the forest service said.

Dominion announced last Friday it would “avoid environmental impacts” by opting to drill in what it calls the “Cow Knob Route Variation,” using horizontal directional drill construction to avoid potential impacts on Cow Knob salamanders and their habitat in the George Washington National Forest on and in the vicinity of Shenandoah Mountain in Highland and Augusta counties, Dominion said in a news release.

The Cow Knob variation was one of four route changes Dominion selected. The concessions did not include avoiding the historic Dividing Waters Farm; Dominion is suing the farm’s owners to survey the land.

Dominion chose other route changes to reduce harming the Cheat Mountain salamander in Randolph County, W.Va.; wetlands and historic district in Nelson and Buckingham counties; and to avoid crossing the Great Dismal Swamp Wildlife Refuge.

The head of the Dominion unit responsible for routing, building, and operating the proposed pipeline said the changes were adequate. “We believe these route adjustments meet the project’s critical need of supplying clean, inexpensive energy to public utility customers while protecting the environmental and cultural resources of communities along the route,” said Diane Leopold, president of Dominion Energy.

Webb drew a map of the Shenandoah Mountain route change based on Dominion’s comments and submitted an aerial photo of a horizontal drill site in West Virginia.

“Significant sedimentation will be unavoidable,” Webb said. “The drilling operation will require large staging areas for the entry points for the drilling operations and major access roads to bring in the drilling equipment, drilling materials, and tanker trucks. A tributary of Shaws Fork, on the western side of Shenandoah Mountain, and Hodges Draft, . . . on the eastern side of Shenandoah Mountain, will be subject to sediment-laden runoff from the staging areas and access roads, which will be built right on top of the streams.”

“Our ongoing study of pipeline construction in the broader region demonstrates that erosion and sedimentation is unavoidable in this type of mountain terrain (and) that the standard best management practices were not designed for steep mountain terrain,” he said this week.

“Hodges Draft is presently a high-quality stream with naturally reproducing brook trout. Brook trout do not tolerate sedimentation,” Webb said. “The brook trout population in Hodges Run is already fragile due to low summer flow levels. Given the length of road and other disturbance in the narrow Hodges Draft valley, it seems likely that the brook trout population will be nearly, if not completely, eliminated.”

Shaws Fork drains into the Cowpasture River, which is a high-quality stream, and which sinks into the underground karst system to emerge eight miles downstream as the source water for the economically important Coursey Springs Trout Hatchery, Webb noted.

“Dominion is pushing the limits of the technology. Technical guidance indicates that horizontal drilling can be done up to about 6,500 feet where grade control is not critical. One of the sections proposed by Dominion will exceed that distance by about 300 feet, and it seems that precise control of the drilling angle would be critical,” he added.

“Another real concern here is that Dominion continues to avoid accountability for its environmental plans and potential impacts. Dominion is not making its specific maps or plans for the drilling operation available to the public. This is a pattern. Dominion also does not plan to make its erosion and sediment control plans available to the public or even the state Department of Environmental Quality.”

Webb noted at least six counties — though notably not Highland — have petitioned state officials to ensure DEQ has the resources to perform proper oversight of pipeline projects. “So far, though, there has been no real response,” Webb said.

“Dominion advertises that it has the highest environmental standards and expects us to trust it. Yet what we have seen at other recent pipeline projects, including a Dominion project, suggests that we would be very foolish indeed to simply trust pipeline construction companies to do the right thing,” he continued. “And then there is the fact that the route modification and proposed drilling will still impact Cow Knob salamander habitat.”

The filing describes the Cow Knob Route Variation as starting on the west side of Shenandoah Mountain along the currently proposed mainline; the route variation initially heads east along a valley for roughly half a mile to the proposed exit point for the first drill point.

From there, the route heads southeast for 1.3 miles to the entry point for the first drill point, which is in a valley along an unnamed tributary to Hodges Draft. This section of the route variation will be installed underneath Shenandoah Mountain by horizontal drilling. The route then continues southeast for about a half mile adjacent to the unnamed tributary to Hodges Draft. The route then heads to the northwest for about 0.6 mile to the entry point for the second drill point, on the east side of Hodges Draft. From here, the route variation continues for 1.1 mile northwest to the exit point for the second drill in a valley along Leslie Lick Hollow. This section of the route variation will be installed beneath a south trending ridge about one mile southeast of Signal Corps Knob. The route then continues southeast, reconnecting to the currently proposed route on a ridge south of Leslie Lick Hollow. A half-mile-long workspace east of the drilling exit point near Leslie Lick Hollow will be required to assemble and string the pipeline, ACP’s filing explains.

Webb said the habitat would still be disturbed and waters would still be polluted. “The information provided in Dominion’s supplemental submission indicates that the modified route will still impact about 0.7 miles of Cow Knob salamander habitat. The disturbance associated with horizontal drilling will also have significant impacts on water resources,” Webb said.

Dominion spokesman Jim Norvelle told the Richmond Times-Dispatch drilling should not add much to the project’s $5.1 billion estimated cost. He did not disclose the drilling distance, but the habitat has been described as accounting for about five miles of the proposal’s 564-mile route.

Dominion’s FERC filing last week states the drilling would be in two sections with a total [route] length of 4.1 miles, two-tenths of a mile shorter than the formerly proposed route.

Dominion says its rationale for re-routing is to avoid salamander lands, but does not concede the forest service’s contention that horizontal drilling does not completely avoid them. Because the Cow Knob Route Variation avoids the Cow Knob salamander habitat areas, reduces tree clearing on Shenandoah Mountain and the ridgeline southeast of Signal Corps Knob, and addresses concerns regarding ORV access to Signal Corps Knob, Atlantic has incorporated this route variation into the proposed route, the filing states.

If approved, the pipeline would move natural gas extracted through hydraulic fracturing from Marcellus shale through Harrison County, W.Va., across Highland southeast through Virginia with an extension to Hampton Roads, and south to Robeson County in southern North Carolina.

Pending regulatory approval, construction is expected to begin in the second half of 2016 and the pipeline is expected to be in service in the fourth quarter of 2018.

Alternate pipeline route and horizontal drilling in Shenandoah Mountain area: an approximation based on narrative submission to FERC. Dominion has designated the route map and drilling specifics "privileged."

Hodges Run area of Shenandoah Mountain.

Staging area for horizontal drilling under Interstate 79 in West Virginia. This Pipeline Air Force photo was obtained this September. The drilling was for the 36-inch-diameter Stonewall Pipeline. The drilling distance was less than 1000 feet. The drilling distances for the proposed 42-inch Atlantic Coast Pipeline would be 1.3 miles and 1.1 miles.

Atlantic Coast Pipeline

The proposed pipeline will cross the central Allegheny Highlands, the Blue Ridge Mountains, and the adjacent valleys. It will cut through 30 miles of national forest and cross numerous rivers, streams, and wetlands. This area represents the heart of the remaining wild landscape in the eastern United States, and it is a major biodiversity refugium that can only increase in rarity and importance.

The proposed pipeline will be 42 inches in diameter, requiring excavation of an 8 to 12-foot-deep trench and the bulldozing of a 125-foot-wide construction corridor straight up and down multiple steep-sided forested mountains. It will require construction of heavy-duty transport roads and staging areas for large earth-moving equipment and pipeline assembly. It will require blasting through bedrock, and excavation through streams and wetlands. It will require construction across unstable and hydrologically sensitive karst terrain.

Pipeline construction on this scale, across this type of steep, well-watered, forested mountain landscape, is unprecedented.

It will be impossible to avoid degradation of water resources, including heavy sedimentation of streams, alteration of runoff patterns and stream channels, disturbance of groundwater flow, and damage to springs and water supplies.

It will be impossible to avoid fragmentation and degradation of intact, high-integrity forests, including habitat for threatened and endangered species and ecosystem restoration areas.